understanding and adopting vaccp and...
TRANSCRIPT
Understanding and adopting VACCP
and TACCP Cathy Lee-Smith 9th November
2017
What does it all mean?
Food Defence and Food Fraud – Some
Definitions
Food Defence - GFSI
The process to ensure the security of food and drink
and their supply chains from all forms of intentional
malicious attack including ideologically motivated attack
leading to contamination or supply failure.
Food safety, food defence, and food fraud risk assessments
consider different criteria in order to determine the degree of
situational risk for each criteria and the measures that need to be
implemented to mitigate that risk.
Food Defence – PAS 96:2014
Procedures adopted to assure the security of food and
drink and their supply chains from malicious and
ideologically motivated attack leading to contamination
or supply disruption
The term food security refers to the confidence with which
communities see food being available to them in the future. Except
in the limited sense that a successful attack may affect the
availability of food, food security is not used and is outside the
scope of this PAS.
Food Fraud
Committed when food is deliberately placed on the market,
for financial gain, with the intention of deceiving the
consumer
Although there are many kinds of food fraud, the two main types are:
• the sale of food which is unfit and potentially harmful, such as recycling of
animal by-products back into the food chain and packing and selling of beef
and poultry with an unknown origin or knowingly selling goods which are past
their ‘use by’ date.
• the deliberate misdescription of food, such as products substituted with a
cheaper alternative, for example, farmed salmon sold as wild, and Basmati
rice adulterated with cheaper varieties or making false statements about the
source of ingredients , i.e. their geographic, plant
or animal origin.
Food fraud may also involve the sale of meat from animals that
have been stolen and/or illegally slaughtered, as well as wild
game animals like deer that may have been poached.
Food Supply
Elements of what is commonly called a food supply
chain
Food Protection
Procedures adopted to deter and detect fraudulent
attacks on food
VACCP
Vulnerability Assessment and Critical Control Points:
Systematic management of risk through the evaluation
of vulnerabilities of (generally) raw materials
Vulnerability = Susceptibility or exposure to a gap or deficiency that
could place consumer health at risk and/or have an economic or
reputational impact on a food company’s operations if not
addressed.
TACCP
Systematic management of risk through the evaluation of
threats, identification of vulnerabilities, and implementation
of controls to materials and products, purchasing,
processes, premises, distribution networks and business
systems by a knowledgeable and trusted team with the
authority to implement changes to procedures
Threat = something that can cause loss or harm which arises from the
ill-intent of people
TACCP and VACCP go hand in hand in the quest to
demonstrate product authenticity. Both are designed to
prevent the intentional adulteration of food:
TACCP identifies the threat of behaviorally or ideologically
motivated adulteration
VACCP identifies how vulnerable various points in the
supply chain are to the threat of economically
motivated adulteration.
Food Defence vs Food Safety vs Food
Security In order to prevent, protect against, mitigate, respond to,
and recover from threats and hazards of greatest risk to the
food supply, it is important that preparedness efforts
encompass food safety, food defence, and food security.
Food Defence - the protection of food products from contamination
or adulteration intended to cause public health harm or economic
disruption
Food Safety - the protection of food products from unintentional
contamination
Food Security - when all people, at all times, have
both physical, social, and economic access to
sufficient, safe, and nutritious food.
Food Fraud Why do we need to do this?
Fraud – Middle Ages (18th & 19th
Centuries)
• Spices
Price of imported spices increased, merchants would
substitute spices with seeds, stones or dusts.
• Milk was commonly diluted with water, sometimes
dirty water, and colored with chalk or plaster
Manuka Honey
Particular type of honey, produced in New Zealand by
bees that pollinate the native Manuka bush... 100%
pure, natural
‘Most precious and priciest honey…. health & beauty elixir (1-hr
facial $179.00)’
Believed value by Advocates - antibacterial properties, skin
treatment e.g. acnes, eczema, cuts, burns, combat ulcers,
infections, digestive aliments and other conditions.
10,000 tons Manuka-labelled honey sold annually, only 1700 tons
of it is actually produced in New Zealand (per Mass spectrometer
analysis of honey four specific compounds that should be present in
Manuka Honey, were NOT).
Recent Past
2013 Horsemeat Burgers
Consumers in England, France, Greece and several other
countries were duped and unknowingly purchased meatballs and
burgers containing meat other than beef. UK Dept. of Agriculture,
Food and Rural Affairs along with Food Standards Agency of
Ireland (FSRI)
Traceability
Identified Meat Sources: 2 processing facilities in the Irish Republic:
• Liffey Meats & Silvercrest Foods and
• the Dalepart Hambleton plant in North Yorkshire
Point of Sale : Dunnes Store, Lidl and Aldi
Analysis:
29% of meat content in one sample (Tesco) – Horse meat
31 beef meal products checked – 10 contained horse
DNA, 21 were positive for pig DNA
Melamine in Infant Formula - 2008
Melamine was being used to dilute milk in order to elevate nitrogen
levels to get higher protein results gain more money. This lead to the
poisoning of many infants and children through contamination of milk
formula and other products.
Peanut tainted Cumin - 2015
Spice supply chain is long and complex.
1 supplier 38 different companies
Nearly 600,000 pounds of beef, pork and chicken
contaminated - Vegetarian products containing the
same ingredients were affected
GFSI defined food fraud as:
“A collective, tampering or term encompassing the
deliberate and intentional substitution, addition,
misrepresentation of food, food ingredients or food
packaging, labelling, product information or false or
misleading statements made about a product for
economic gain that could impact consumer health.”
GSFI requires that a Food Fraud Vulnerability Assessment be
completed and documented and a Food Fraud Prevention
Strategy be applied across the Food Safety Management
system.
Opportunity +
related to Fraud
Risk Factors
Motivation -
related to Fraud
Risk Factors
Controls
Fraud Control
Measures
= Actual Fraud
Vulnerability
FOOD FRAUD
Substitution
Concealment
Mislabelling
Grey Market Production/
Theft/ Diversion
Unapproved Enhancement
Counterfeiting
Dilution
• Watered down product using unsafe water
• Olive oil diluted with potentially toxic tea tree oil
• Sale of excess unreported product
• Copies of popular foods
• Not produced with acceptable safety assurances
• Poultry injected with hormones to conceal disease
• Harmful colourings added to F&V to conceal defects
• Expiry, Provenance (unsafe origin)
• Toxic Japanese Star Anise labelled as Chinese Star Anise
• Melamine added to enhance protein content
• Use of unauthorised additives (Sudan Dye)
• Sunflower oil partially substituted with mineral oil
• Hydrolysed leather protein in milk
Economically Motivated Adulteration
• In 2013, allegations were reported that a food factory in Asia
was labelling cooking oil as peanut, chilli and olive when it
contained none of these oils.
• A 2013 report suggested that one third of retail fish in the
USA was mislabelled. Examples included, tilapia sold as red
snapper and tilefish sold as halibut.
• In 2010, some producers of buffalo mozzarella in Italy were
accused of adulteration of their product with cow’s milk
• Staff in a European meat packer felt, mistakenly, that they
could avoid a product being condemned as
carrying foot and mouth disease by covering
it with disinfectant.
Malicious Contamination
• In 2005, a major British bakery reported that several customers
had found glass fragments and sewing needles inside the
wrapper of loaves.
• In 1984, the Rajneeshee sect in Oregon attempted to affect the
result of a local election by contaminating food in ten different
salad bars, resulting in 751 people affected by salmonella food
poisoning.
• In 2013, a major soft drinks supplier was forced to withdraw
product from a key market when it was sent a bottle which had
had its contents replaced with mineral acid. The attackers
included a note indicating that more would be distributed to the
public if the company did not comply with their demands.
• In 2007, a bakery found piles of peanuts in the factory. It withdrew
product and closed for a week long deep
clean to re-establish its nut-free status.
Extortion
Espionage
Counterfeiting
• In 2013, enforcement officers
seized 9 000 bottles of fake
Glen’s Vodka from an illegal
factory.
• In 2011, 340 bottles of Jacobs
Creek wine were seized, following
complaints of poor quality to the
owner, which had no link with
Australia.
Cyber Crime
• In 2014, Financial Fraud Action UK advised restaurant
managers to stay vigilant as fraudsters are attempting to
target their customers in a new phone scam. They phone
restaurants claiming there is a problem with their card
payments system, the restaurant is then told to redirect any
card payments to a phone number provided by the fraudster
Understanding the Aggressor
• The extortionist
• The extremist
• The irrational individual
• The disgruntled individual
• The hacktivist and other cyber criminals
• The professional criminal
• The opportunist
Prevention Methods
• Conduct a Documented Food Fraud Vulnerability Assessment
• Target all types of Food Fraud
• Implement Documented Food Fraud Prevention Strategy
• Conduct an annual Food Fraud Incident Review
Confirm that the scope covers all products; including both
incoming goods (e.g. ingredients) and outgoing goods (e.g.
finished goods) to the consumer.
VACCP & TACCP Assessments How do we do this?
Vulnerability Assessment - WSEP
List of Materials
Map Out Supply Chain
Evaluate Risk
Assess Need for Additional control
Record Findings
Review at least annually
Vulnerability Assessment – PAS 96
Vulnerability
Assessment
- SSAFE
SSAFE is a non-profit membership driven organization that aims to foster the continuous improvement and global acceptance of internationally recognized food protection systems and standards through public private partnerships In 2015 they developed a tool that will help any food business, irrespective of geographical location or size, determine where they may be vulnerable to fraudulent activities and prepare control plans. The tool will be available in three versions - in excel, on the web and as an app - and will be free of charge.
Outline of the 15-step TACCP Process
Risk Assessment
• Can be done in many different ways
• Often can utilise current risk assessment tools to
assist.
• Examples include
• Likelihood vs Impact (PAS96)
• Priority Risk Number (PRN) Matrix (BRC)
Likelihood vs Impact Risk Assessment
Likelihood and Impact
PRN Matrix
PRN Rating
Carver-Shock
This is the tool used by the military targeting weaknesses by
assessing their:
• Criticality
• Accessibility
• Recognisability
• Vulnerability
• Effect
• Recoverability
Carver-Shock
Team members put themselves in the place of the
prospective attacker and ask:
If I wanted to cause harm, or make more money, or
gain publicity, or take advantage of the situation in
some other way:
• What would I do?
• Where would I do it?
• When would I do it?
Summary - Key Steps to Food Defence
• Broad Mitigation Strategies
• Vulnerability Assessments
• Focused Mitigation Strategies
• Food Defence Plan
Examples of Vulnerability Assessment
Methods: Vulnerability Assessment Methods - Food Fraud Advisors
www.foodfraudadvisors.com/vulnerability-assessment-methods
SSAFE and PwC tool helps assess vulnerability to food fraud
www.foodqualitynews.com/Industry-news/SSAFE-and-PwC-tool-helps...
FDA food fraud vulnerability assessment_pdf
www.docscrewbanks.com/pdf/fda-food-fraud-vulnerability-assessment
VACCP: HACCP for vulnerability assessments | 2016-02 …
www.foodengineeringmag.com/articles/95205-vaccp-haccp-for...
Vulnerability Assessment Tools - Food Fraud Advisors
www.foodfraudadvisors.com/vulnerability-assessment-tools
A tool to help you with food fraud vulnerability assessments.
Examples of Self-Assessment Tools:
SSAFE and PwC tool helps assess vulnerability to food fraud
www.foodqualitynews.com/Industry-news/SSAFE-and-PwC-tool-helps...
Vulnerability Assessment Tools - Food Fraud Advisors
www.foodfraudadvisors.com/vulnerability-assessment-tools
The Vulnerability Assessment Tool v2.0 and the Vulnerability
Assessment Tool (BRC method) are Microsoft Excel Spreadsheets that
are designed to help you
U S Food and Drug Administration (FDA)
Vulnerability Assessment Software
http://www.fda.gov/Food/FoodDefense/ToolsEducationalMaterials/ucm29
5900.htm
Examples of Other Guidance Documents:
– U.S. Pharmacopeia Appendix xvii : Food fraud mitigation guidance
http://www.usp.org/sites/default/files/usp_pdf/ EN/fcc/food-fraud-mitigation-
guidance.pdf
– BRC Global Standard for Food Safety Issue 7 Understanding
Vulnerability Assessment http://www.brcbookshop.com/p/1782/brc-global-
standard-for-food-safety-issue-7-understanding-vulnerability-assessment-
ukunlocked- pdf-version
– UK Food and Drink Federation (FDF)
http://www.fdf.org.uk/corporate_pubs/Food- Authenticity-guide-2014.pdf
– TACCP (Threat Assessment and Critical Control Point): a practical guide
2014 (Campden BRI)
http://www.campdenbri.co.uk/publications/pubDetails.php?pubsID=4640
Thank You
www.takeoffconsulting.com.au